Comment from David Johnston
David JohnstonOpposeGovernment
Summary: An employee of a state public health department opposes the proposed regulation, arguing that discretionary termination of federal grants based on political considerations would disrupt public health work and cause a loss of institutional knowledge. They also contend that unilaterally changing the conditions of congressionally appropriated funds via rulemaking constitutes a significant governmental overreach.
As an employee of a state public health department, I regularly work with the federal government on grants and cooperative agreements that the state has received. These include such CAs as ELC, PHEP, HPP and others. Discretionary termination of these awards based solely on political considerations would be extremely disruptive to the work of Public Health. Stopping projects in the middle a cycle not only disrupt those projects but also causes the loss of institutional knowledge and expertise to work on other projects. These are funds specifically appropriated by Congress with specific conditions, unilaterally changing these conditions via rulemaking seems to be a significant governmental overreach.